RE: 100 mrem criterion, radiation worker

["Migliore, Charles W" <Charles.W.Migliore@nspco.com>]

"and logically to the point that if a worker gets no more dose
than allowed for a member-of-the-public why should the training requirement
related to the rad exposure component of the work be any different than
that for a member-of-the-public."

Perhaps legal liability concerns drive this more than the science does.

IMHO,
Charles MIgliore RRPT


> -----Original Message-----
> From:	Les Slaback [SMTP:lester.slaback@nist.gov]
> Sent:	Tuesday, April 20, 1999 8:13 AM
> To:	Multiple recipients of list
> Subject:	100 mrem criterion, radiation worker
> 
> One reason NRC made the change to 10CFR19 and to the definition of
> occupational dose was that a person, e.g., a member-of-the-public, should
> not be categorized as a radiation worker simply by entering a restricted
> area.  Once you decide to drop that definition (dating back to the old
> Part
> 20) you are faced with how to define Occupational Dose, which is now based
> on function (i.e., duties performed).  This then leads to graded training
> requirements, and logically to the point that if a worker gets no more
> dose
> than allowed for a member-of-the-public why should the training
> requirement
> related to the rad exposure component of the work be any different than
> that for a member-of-the-public.
> Similarly NRC not long ago made a change to the threshold requirement for
> monitoring of minors (i.e., changing the threshold from 50 mrem to 100
> mrem).
> Personally I think these changes make for a much more logical and
> consistent set of rules.
> 
> Regarding RADIATION WORKER ....
> There are a number of definitions floating around, and folks commonly
> associate anyone getting Occupational Dose (as defined by NRC) as being a
> RW.  But the fundamental issue is what are the regulatory requirements
> related to the definition.  As seen by the previous RADSAFE discussion in
> the NRC world there is a large gray area.  That is, while the definition
> of
> Occupational Dose is clear cut (well, sort of) the related requirements
> for
> dosimetry and training are varied, and in some cases minimal to nil.
> Similarly, the responses to France query indicate that their medical test
> requirements vary, depending on the kind of rad work and level of
> exposure.
>  Hence what is implied by the use of the term Radiation Worker depends
> upon
> the context.  And the context is not the same even among different U.S.
> areas (DoE, NRC, state regulated licensees).
> 
> OPINION
> Lastly, I assert that at exposures within occupational limits there is no
> need for medical exams or medical screening criteria related to the
> radiation exposure component of the work.  If you accept the stochastic
> model of risk expression and current estimated risk levels I do not see
> how
> one can justify any other position.  [We'll see what that stirs up.  But
> that is basically NCRP's position.]
> 
>     Subject: Re: Medical examination for a radiation worker
> Steve Hand wrote........
>     I find it interesting that our Agreement State Regulations do not have
> the
> same first paragraph as 10 CFR 19 which you have written as "This is the
> section..."  Instead our regulations say "All individuals working in or
> frequenting any portion of a restricted area:  shall "  etc...  rather
> than
> "when a worker exceeds the 1 mSv (100 mrem) threshold:"   <snip> ........
> 
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